Our report for the European Sustainable Phosphorus Platform (ESPP) sets out key questions for policymakers considering a possible quota system for recycled phosphorus in fertilisers.
Phosphorus is a vital element in agriculture, but phosphate rock is a listed EU Critical Raw Material and Europe is heavily reliant on imports from a small number of countries. Transitioning from the current linear phosphorus economy to a circular economy is vital for sustainable phosphorus use, resilient agriculture, and global food security. As a result, recovery and recycling of phosphorus is receiving growing interest from European policymakers and industry.
A recycled phosphorus quota for fertilisers would be a regulatory mechanism mandating that a certain percentage of phosphorus content in fertilisers be derived from recycled sources. While such an approach could help stimulate demand for recovered phosphorus and support the development of a circular market, it also raises practical and policy considerations.
To explore these considerations in a structured way, we derived 44 questions that policymakers should take into account if considering a quota system for recycled phosphorous in fertilisers. These were derived from a review of literature and stakeholder consultation between October – November 2025. We interviewed a range of experts and practitioners including representatives of fertiliser producers, the water industry, recycling technology companies, research, and waste management.
The questions produced fall under the following broad themes:
- What would be the aim of a recycled phosphorus quota system?
- Who should the quota apply to?
- How would the quality of recovered phosphorus and fertiliser products be ensured?
- How high would the quota be?
- What would be the geographical scope and regulatory context of the quota system?
- What would be the burdens of implementing a quota system?
- Would quotas be tradeable?
- How would imports and exports be accounted for in a quota system?
These questions are intended to bring a practical perspective; to guide thinking on the potential effectiveness, fairness, feasibility, and possible co-benefits or unintended consequences of developing and implementing a quota system for recycled phosphorus in fertilisers.
